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Klocek v. Gateway, Inc. - 2000 U.S. Dist. LEXIS 21854 (D. Kan. Sep. 6, 2000)

Rule:

Each plaintiff in class action diversity action must meet the jurisdictional amount in controversy; aggregation is allowed only if plaintiffs unite to enforce a single title or right in which they have a common and undivided interest.

Facts:

Plaintiff William S. Klocek filed a putative class action lawsuit in federal district court against Gateway, Inc. ("Gateway") and other defendants. The lawsuit stemmed from Klocek's purchase of a computer from Gateway. Gateway filed a supplemental motion to dismiss and compel arbitration. Gateway asserted that the district court lacked diversity jurisdiction under 28 U.S.C.S. § 1332(a) because Klocek could not in good faith claim that the amount in controversy exceeded $ 75,000. In response, Klocek stated that based on lack of subject matter jurisdiction, he joined in Gateway's motion to dismiss. Klocek further stated that he filed his complaint in reliance on a ruling from a federal appellate court which allowed a plaintiff to aggregate class claims for punitive damages to meet the amount in controversy requirement; that ruling, however, was later abrogated by another decision from the same appellate court.

Issue:

Should the court grant the motion to dismiss?

Answer:

Yes.

Conclusion:

The court granted Gateway's motion to dismiss for lack of subject matter jurisdiction; the court did not address Gateway's request to compel arbitration. The court noted that while a plaintiff was not necessarily required to specify an exact amount of punitive damages, he must allege enough facts to convince the court that recoverable damages bore a reasonable relation to the minimum jurisdictional requirement. In light of Klocek's concession that the court lacked subject matter jurisdiction, the court found that Gateway's motion to dismiss should be sustained.

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